Importing gold into Hong Kong: what a buyer must have in place

Who the rules bind

Since 1 April 2023, dealers in precious metals and stones have been regulated under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), administered by the Customs and Excise Department. Customs' Registration Guide (May 2026) says the regime covers gold "in a manufactured or unmanufactured state", so it reaches doré as well as bars, and sets no purity threshold. A precious metals and stones business includes trading in, exporting or importing gold, refining it, and acting as an intermediary. A logistics firm that only imports or exports in the ordinary course of its business is excepted.

Registration is triggered by the size of the deal. A specified transaction is one in which payments of at least HK$120,000, or the equivalent in another currency, are made or received in Hong Kong other than in cash, in one operation or in several that are linked. A specified cash transaction is the same amount in cash. A dealer whose deals are never in cash applies for Category A registration; a dealer who takes or makes cash at that level applies for Category B. Carrying out either kind of transaction unregistered is an offence with a maximum fine of HK$100,000 and six months' imprisonment.

A non-Hong Kong dealer is exempt from registration: an individual not ordinarily resident, or a company incorporated outside Hong Kong that is not registered there, with no place of business in Hong Kong and business carried on there for no more than 60 days in a calendar year. That dealer must still file a cash transaction report with Customs for any cash deal of HK$120,000 or more carried out in Hong Kong, before the earlier of one day after the deal or leaving Hong Kong. Failure carries a maximum fine of HK$50,000 and three months.

The texts we read do not say whether a wire sent by a Hong Kong importer to a seller overseas is a payment "made in Hong Kong". That is a question for a Hong Kong adviser, not an answer we can give.

What to have in place before a shipment

The file a Category B dealer keeps

The Guideline says a Category B registrant must carry out customer due diligence before establishing a business relationship involving a specified cash transaction, before an occasional one, when it suspects money laundering, and when it doubts the information it holds. The measures are to identify the customer and verify identity from reliable documents, to identify and take reasonable measures to verify any beneficial owner, and to obtain information on the purpose and intended nature of the relationship. Records are kept for at least five years.

The Guideline names "precious metals or stones with a worldwide standard and reference price published daily" as a higher-risk product. It contains no supply-chain or origin rule: the words "OECD", "conflict" and "supply chain" do not appear in it. That is absence in what we read, not permission. Refiners and banks set their own origin requirements, and a Hong Kong buyer will ask a Ugandan seller for the same chain-of-custody documents a buyer anywhere else would (see gold chain of custody and what each export document should prove).

Why gold declared as Ugandan gets a closer look

On Uganda's own 2025 export figures, Hong Kong was the second recorded destination for Ugandan gold, at 11,782 kg, after the UAE at 48,524 kg. Uganda recorded about 62 tonnes of gold exports in 2025, and United Nations experts assessed that the rise was largely attributable to gold originating in the Congo. See Uganda's production and export figures.

We found no Hong Kong text that names Uganda or sets a rule specific to Ugandan gold. The regime is a dealer-registration and anti-money-laundering framework, so the questions will come from the dealer's own risk assessment and its bank's: who mined the gold, which licence it moved under, and whether the export permit, assay and shipping papers describe the same lot. Expect specific questions on mine-level origin.

Duty, tax and reporting

The free-port position and the market

Hong Kong's position is that nothing is paid at the border on gold, but the paper trail is not optional: gold is not an exempted article, so the 14-day declaration applies, and dealing above HK$120,000 needs registration. The Hong Kong Gold Exchange describes itself as "Hong Kong's Sole Physical Gold and Silver Exchange", providing an exchange and facilities to its members, and publishes a member list and a list of recognised refiners. Customs' Guide names its physical gold and silver contracts as an example of precious-asset-backed instruments. We describe it as a market, not an endorsement: we did not read its membership or refiner rules, and the former cgse.com.hk address returned a 404 error when we tried it. For what a bar buyer usually asks for, see gold bar specifications.

Can a private individual import gold?

We did not find an answer. The registration duty applies to a person carrying on a precious metals and stones business, and the texts we read do not define "by way of business" for an individual importing for themselves. Ask a Hong Kong adviser or customs broker before you commit.

The Ugandan side of the shipment

Under Uganda's Act, each consignment needs an export permit. The copy of Uganda's 2024 export regulations we reviewed states a minimum of 99.9% gold for exports (S.I. 30 of 2024, regulation 3). We have not confirmed that it is currently in force, and we found no exemption for doré. This is a regulatory requirement, not a product specification, and a buyer's acceptance of any material is a separate matter. Qualified Ugandan legal advice is still needed on how it applies today. See how gold is lawfully exported from Uganda and how to check a Ugandan gold supplier.

What we could not confirm

• Whether a Hong Kong importer's wire to an overseas seller is a payment "made in Hong Kong" for the HK$120,000 test
• What "by way of business" means for a private individual importing for personal holding
• The Hong Kong Gold Exchange's membership and refiner rules, and any bar standard it applies
• Whether "funds" under the Cap. 537 regulations for the Democratic Republic of the Congo include bullion
• How doré is classified in a Hong Kong import declaration
• The Ordinance text itself: today we read Customs' Guide and Guideline, not Cap. 615

Where Uganda Gold Report stands

Uganda Gold Report is developing documented gold-sourcing routes and welcomes enquiries from qualified international buyers. Product availability, specifications, seller authority and export eligibility are subject to independent verification and applicable regulatory approvals. We do not supply Hong Kong, and we have no buyers, refiners or partners there; we hold no stock and no Ugandan licence. If you are a buyer with a genuine requirement, send us your specification and delivery point. We reply with what can and cannot be quoted at this stage.